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The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) is a complicated and often misunderstood law. Its critical importance to the food and agricultural sectors of the global economy knows no bounds, however, and the business of pesticides is central to those sectors’ successes. State pesticide programs are also important, and increasingly a part of the commercial process in states beyond California and New York.
What We Do
Acta professionals routinely advise clients on a full range of FIFRA issues, including registration, reregistration, compliance, and defense. Our FIFRA work includes the following:
- Product Registration, Reregistration, and Registration Review –
- Assist clients across registration, reregistration, and registration review issues, such as:
- Pesticide Registration Improvement Extension Act of 2018 (PRIA 4) matters
- Reregistration Eligibility Decision (RED) and Registration Review decision documents
- California and other state registration requirements
- Assist clients across registration, reregistration, and registration review issues, such as:
- Compliance –
- Counsel clients on compliance matters, including those affecting marketing materials and claims, product production requirements, recordkeeping and reporting requirements, and data submission requirements
- Train client personnel, from management to sales and marketing personnel, on FIFRA compliance
- Marketing –
- Counsel clients on product promotion that is EPA and U.S. Food and Drug Administration (FDA) compliant
- Address issues affecting product marketing under EPA’s treated article exemption
- Assist clients in obtaining EPA approval of expanded claims for products
- FIFRA Enforcement –
- Defend products in enforcement matters involving, among other issues: labeling, export/import, and experimental use permits
- Defend products in proceedings involving, among other issues: Notices of Intent to Suspend, cancellations, and special reviews
- Data Compensation
- EPA/FDA Dual Jurisdiction Issues
Our Experience
Acta professionals have substantial experience in the developing regulation and policy of products implicated under FIFRA.
Lynn L. Bergeson has assisted clients for over 30 years in resolving and advocating on often precedent-setting, novel, and complex pesticide regulatory issues. Ms. Bergeson is engaged in the evolving law and policy of nano pesticides and biopesticides.
Lisa M. Campbell has worked on some of the toughest FIFRA issues of our time, tackling the intersection of pesticide law and public policy. Ms. Campbell’s extensive work includes organophosphates, soil fumigants, commodity fumigants, antimicrobials, and other hot button FIFRA and Food Quality Protection Act (FQPA) issues.
Lisa R. Burchi delivers more than 18 years of skilled work on virtually every aspect of FIFRA, including registrations, establishments, FIFRA Section 6(a)(2) reporting, imports/exports, devices, treated articles, and supplemental registrations. Ms. Burchi lives and is licensed in California and has extensive knowledge of California’s state regulatory system.
James V. Aidala has over 30 years of experience in the field of pesticide legislation, policy, and implementation. Before joining Acta, Mr. Aidala was Assistant Administrator of EPA’s Office of Prevention, Pesticides, and Toxic Substances (OPPTS) (now the Office of Chemical Safety and Pollution Prevention (OCSPP)). Both at EPA and during earlier work for Congress’s Subcommittee on Environment, Energy, and Natural Resources, Mr. Aidala was deeply involved in FIFRA matters, in charge of oversight of EPA’s implementation of FIFRA while working on Capitol Hill.
Heather F. Collins, M.S., works with pesticide producers to ensure FIFRA compliance, including determining data requirements, label requirements, and registration requirements. Ms. Collins has specific expertise in biocide and pesticide compliance strategies under FIFRA.
Kelly N. Garson assists clients with data compensation negotiations, FIFRA enforcement actions and settlement negotiations, and issues relating to EPA registration review decisions. She prepares guidance on EPA’s labeling requirements and pesticide claims and has assisted on advocacy efforts relating to EPA’s policies regarding “absence of ” product claims.
Dana S. Lateulere draws upon her 30 years of pesticide regulation experience, including a decade with the EPA Office of Pesticide Programs (OPP), as she assists clients in preparing and submitting new product submissions and registration review responses, managing lab work and data procurement, and composing compliant label systems.
Jane S. Vergnes, Ph.D., DABT®, has 25 years of toxicology and product stewardship experience with major international chemical companies that manufacture FIFRA-regulated products. She is a tremendous asset to those clients needing data review and interpretation, study monitoring, hazard characterization, or assistance in preparing data for submission to EPA.
Todd J. Stedeford, Ph.D., DABT®, ERT, ATS, delivers exceptional legal acumen and scientific experience to clients registering and defending pesticide products. Dr. Stedeford most recently served as Senior Science Advisor/Senior Leader, Office of Pollution Prevention and Toxics (OPPT), OCSPP. Previous positions include Acting Chief, the Chemical Risk and Reporting Enforcement Branch, Waste and Chemical Enforcement Division, Office of Civil Enforcement (OCE), and Chief of Assessment Branch 2 for New and Existing Chemicals, Risk Assessment Division, OPPT.
Lara A. Hall, M.S., RQAP-GLP, assists clients through various aspects of product registration under FIFRA, including data development (study monitoring, third party quality assurance, and fate and effects modeling) and responses to EPA Data Evaluation Reports. Additionally, Ms. Hall assists in maintaining and updating extensive datasets for pesticides and antimicrobial products to support registration requirements.
Scott J. Burya, Ph.D., a Regulatory Chemist with a Ph.D. in analytical chemistry, managed compliance and notification activities for biocides and antimicrobials used in antifouling and industrial coatings for a multinational coating manufacturer. Dr. Burya specializes in reviews and quantitative risk assessments.
Representative Engagements
- Acta is among the elite in pesticide practice and policy firms representing global product manufacturers on virtually every aspect of FIFRA/FQPA policy, science, and regulation.
- Acta assists both large and small product manufacturers and trade associations in tackling the daunting array of scientific, regulatory, and policy challenges confronting the agricultural chemical community. Acta professionals are intimately familiar with the legislative underpinnings of FIFRA and FQPA, and continue to work on legislative matters arising under FIFRA, the Clean Water Act (CWA), the Endangered Species Act (ESA), the Pesticide Registration Improvement Act (PRIA), and other laws applicable to agricultural practices.
- Acta’s expertise extends to registration and related responsibilities as required in each state in which a pesticide product is sold or distributed. California is one example of a state imposing additional or distinct requirements for state registration (e.g., data development, label restrictions) and other state-specific requirements, including Proposition 65 and pesticide mill assessments.
- Acta routinely assists data owners in protecting and optimizing their financial investment in FIFRA registration data relied upon by follow-on registrants and in negotiating data compensation settlements or assisting in data compensation arbitrations when settlement is not an option.
- Acta professionals have procured countless successes for clients in obtaining novel registrations, continuing challenged registrations, and/or diminishing the regulatory constraints on existing registered products.